Regulation of Health and Social Care Professionals Consultation

above. The Council for Healthcare Regulatory Excellence has reviewed this area
and made its own recommendations on some common terms. 89 In particular, the
report concluded that “striking off” was to be preferred to alternative terms such
as “erasure” and “removal” because it was seen by the public as reassuring and
authoritative. 90 Alternatively, “striking off” may have punitive connotations and
might not provide clarity about the purpose of the sanction which is to remove a
registrant from their practice environment to ensure patient safety.
9.118 There are also various terms used to describe warnings across the regulators,
such as caution, admonishment or reprimand. In our view, the terms caution and
warning are more readily understandable than admonishment or reprimand. We
believe the most appropriate term is warning because this has a more formal
connotation, whilst a caution can be interpreted as a slap on the wrist. We also
welcome views on the terms used to describe consensual forms of disposal.
Provisional Proposal 9-24: All Fitness to Practise Panels should have powers
to impose the following: (1) erasure from the register; (2) suspension; (3)
conditions; and (4) warnings.
Provisional Proposal 9-25: The Government should be given a regulationmaking
power to introduce systems of financial penalties and cost awards.
Provisional Proposal 9-26: All Fitness to Practise Panels should have powers
to agree undertakings and voluntary erasure.
Provisional Proposal 9-27: The regulators should have powers to introduce
immediate orders (or use Interim Orders for this purpose).
Provisional Proposal 9-28: The test for imposing any of the sanctions listed in
provisional proposal 9-24 and consensual disposals in 9-26 should be to
protect, promote and maintain the health, safety and well-being of the public
(and maintain confidence in the profession).
Provisional Proposal 9-29: The regulators should be given broad powers to
make rules in relation to the sanctions listed in provisional proposal 9-24 and
consensual disposals in provisional proposal 9-26.
Provisional Proposal 9-30: The Government should be given a regulationmaking
power to add new sanctions and consensual disposals to those listed
in provisional proposals 9-24 and 9-26, and to remove any sanctions and
consensual disposals.
Question 9-31: Does the language used in the proposed list of sanctions and
consensual disposals contained in provisional proposals 9-24 and 9-26
convey accurately their purpose?
89
Council for Healthcare Regulatory Excellence, Harmonising Fitness to Practise Sanctions:
Common Terms (2009).
90 As above, p 2.
186